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HomeMy WebLinkAboutCOC rbc-jan-10-2011-industry.pdfINDUSTRY |COMMENT JANUARY 10, 2011 GRRRRRowth = High Voltage Investment (Good Regs+Retrofit+Retire&Replace+Renewables) We take a refined regulatory view in evaluating the industry and then layer in growth, dividends, and unregulated subsidiaries. A strong regulatory environment must be considered in tandem with growth profiles of utility companies. If a proper regulatory foundation is not in place, growth can actually impair the financial health of utilities. Given regulatory constructs, growth prospects, upcoming catalysts and current valuations, we expect CMS, NVE, PNM and SO to outperform the space in 2011. Key Drivers of Favorable Regulatory Environments Include: Small, simple, and routine general rate cases:General rate cases typically weigh down utility stocks until resolved. Keeping requests small, stripping out as many elements as possible, and filing them regularly minimizes rate case risk and benefits shareholders. Forward ratemaking = ROE realization:Eliminating regulatory lag with forward ratemaking enables companies to realize approved ROEs on a consistent basis. Getting rewarded for large-scale investment risk:Receiving specific approval for large projects, recovery of financing costs during construction, and automatic inclusion in rates once online reduce financing costs and support ROE realization. Key Near Term Growth Topics Include: Environmental Compliance spending still job #1:EPA final rulemaking in 2011 should prompt utilities to finalize fleet compliance plans. Retrofits, retirements, and replacement capacity should comprise a bulk of utility capital spending in the near term. Build Green:Companies operating in states with Renewable Portfolio Standards (RPS) can add to rate base by building the required generation or associated transmission under these mandates. Load Growth, still playing catch-up for now:Industrial volumes are up thus far in 2010, but remain well below recent levels. We expect the positive trending to continue, but likely not enough to trigger new capacity capital spending in the near term. Other Utility Considerations: Steady and growing dividend:Dividends remain the backbone of utility investing. Barring substantial catalysts, dividend yields must remain competitive with current averages of 4.3%. Unregulated Subsidiaries tip the scale:These segments represent an X factor that could swing investor sentiment in one direction or another. We prefer unregulated operations that 1) provide steady cash flows, 2) do not introduce considerable risk, 3) overlap with existing utility expertise, and 4) present growth opportunities. Priced as of prior trading day's market close, EST (unless otherwise noted). All values in USD unless otherwise noted. RBC Capital Markets, LLC Emily Christy (Analyst) (212) 428-6970; emily.christy@rbccm.com Lasan Johong (Analyst) (212) 428-6462; lasan.johong@rbccm.com Ella Vuernick (Associate) (212) 428-6492; ella.vuernick@rbccm.com Companies under Coverage: (Company, Ticker, Rating*, Current Price, Target Price, Risk) *O=Outperform, SP- Sector Perform, U= Underperform For Required Conflicts Disclosures, see Page 28. 2 Emily’s Scouting Report We examine four major business drivers when evaluating regulated utilities: 1) regulatory environment, 2) growth prospects, 3) unregulated subsidiary contribution, and 4) dividends. In this note we will examine these four business drivers and provide both industry and company outlooks across our covered universe. Emily’s Scouting Report below summarizes our conclusions. Shading reflects our view on which elements should improve (green) or worsen (red) in 2011. An expanded version with the supporting data is found in Exhibit 15 on page 15 of this note. We intend to use this report as an ongoing measure of our views on the evolving industry and company trends. Exhibit 1: Emily’s Scouting Report Regulatory Rating1 General Rate Cases Forward/ Historical Ratemaking Treatment of Large-Scale Investments Realized ROE Key Rating Drivers CMS O ++==+==Transformational story NVE O +==--NA -Rate relief should increase ROE PNM O ++=-=+-Regulatory progress = investor confidence SO O ++++=++Industry-leading fundamentals TE SP =+=+--=Coal risk UTL SP =-NA -==+Rate case risk in new region DTE SP =+====+Rate case risk, Energy Trading DUK SP =-=-+-+Rate case risk, IN investigation NEE SP -+=+++=Regulatory overhang, quiet subs IDA U -===+NA -Rate case risk, weak dividend Unregulated Subsidiaries Dividend Yield Growth 1) O= Outperform, SP= Sector Perform, U= Underperform Source: RBC Capital Markets, Company reports, FactSet 1) Regulatory Environment: They Say Who, They Say When, They Say How Much A supportive regulatory environment is paramount to utility financial health. Operating expenses are only recovered to the extent regulators approve the costs. Growth can only benefit shareholders if regulators allow the utility to recover capital costs and earn favorable returns on investments. Having a reasonable allowed ROE and mechanisms in place to realize it are hallmarks of favorable regulatory environments. The most important elements of a regulatory structure toward that end are: a) Small, simple, and routine general rate cases; b) Forward ratemaking; and c) Separate treatment of large-scale investments with pre-approval and recovery of costs during construction. We examine these elements one by one and address the associated regulatory metrics found in Exhibit 1, the covered universe snapshot. Shaded columns in the following regulatory exhibits are found in the snapshot. We also examine smaller regulatory considerations including temporary rate structures, decoupling, and regulatory treatment of energy efficiency. a) General Rate Cases: Shrinking the Elephant in the Room When a company submits a general rate case, all eyes focus on the regulatory environment and investors in the stock typically stay on the sidelines until the rate case is resolved. This impacts utilities that only operate in one jurisdiction to a much greater extent than those companies with diversified regulatory exposure. Utilities can minimize this rate case risk in certain jurisdictions by keeping increases small, focused, and frequent enough to be handled as a matter of routine. Additionally, quick resolution of rate cases is preferable. When these factors are present, rate case success rates are typically above the average ~60% mark. Recent rate case results from across our coverage universe are found in Exhibit 2 at the end of this section. Regulatory Structural Support in Simplifying Rate Cases General rate cases are typically more successful when they are stripped of as many recovery elements as possible. Jurisdictions that exclude costs for new generation, environmental retrofits, energy efficiency programs, and fuel expenses are generally preferred. This GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 3 keeps the rate case digestible for regulators, the increases smaller for ratepayers, and the process less risky for investors. Regulatory models that embrace this structure include Alabama, Florida, Indiana, and Mississippi. Favorable Rate Case Strategies Frequent Filings Aside from the structure elements of a particular jurisdiction, in many cases utilities can file rate cases at their discretion. Frequent rate cases can reduce regulatory risk. If regulators become familiar with the utility needs on a regular basis, rate cases become more manageable. Additionally, if rate cases occur more often, the requested increases are typically smaller. Small increases every year raise less intervener eyebrows than larger increases every few years. That being said, fully litigated rate cases filed annually can cause regulatory fatigue. This is particularly a risk if the rate cases are not simplified. A clear example of this model in recent rate cases is PNM. The company filed its first rate case in over 20 years in 2007 and received 44% of its request. The initial staff recommendation was only 16%. PNM filed another rate case the following year and was awarded 69% of its request. Settlement Instead Of Litigation Rate cases that conclude in six months or less reduce the risk overhang of the rate case process. While few jurisdictions operate within this short time frame, utilities can settle cases to shorten the process. Across our coverage, settled rate cases have lasted an average of 200 days, compared to 300 days for fully litigated rate cases. Additionally, utilities typically do not settle unless the outcome is reasonable. An acceptable outcome and a shortened process bodes well for shareholders. Exhibit 2: General Rate Case Summary Rate Case Revenue Increase ($MM) % of Allowed Days to Rating Subsidiary Year Requested Approved Request ROE Resolve CMS O CMS Electric - MI 2010 $178 $146 82.0% 10.7% 287 CMS Gas - MI 2010 $89 $66 74.2% 10.6% 360 NVE O NVE - South - NV 2009 $311 $223 71.7% 10.5% 205 NVE-North - NV 2008 $111 $87 78.4% 10.6% 210 PNM O PNM Electric - NM 2009 $111 $77 69.4% 10.5% 248 TNMP - TX 2010 $20 $10 51.0% 10.1% 106 SO O Georgia Power - GA 2010 $809 $562 69.5% 11.2% 173 DTE SP Detroit Edison - MI 2010 $378 $217 57.4% 11.0% 350 MichCon - MI 2010 $171 $119 69.6% 11.0% 359 DUK SP Electric - NC 2009 $496 $315 63.5% 10.7% 140 Electric - SC 2009 $133 $74 55.6% 11.0% 120 Gas - KY 2009 $18 $13 74.3% 10.4% 159 Electric - OH 2009 $86 $55 64.0% 10.6% 279 Gas - OH 2008 $34 $18 53.4% 10.6% 255 NEE SP FPL - FL 2010 $1,000 $75 7.5% 10.0% 364 TE SP Tampa Electric - FL 2009 $228 $138 60.5% 11.3% 218 Peoples Gas - FL 2009 $27 $19 72.5% 10.8% 267 IDA U Idaho Power - ID 2009 $67 $27 40.3% 9.5% 219 Blended Metrics 63.2% 10.7% 241 Source: Company reports, RBC Capital Markets GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 4 b) Forward Test Year Crucial To Eliminating Regulatory Lag Regulatory Lag Lowers ROEs Regulatory lag is usually the prime culprit when utilities fall short of realizing their approved ROEs. When utilities request rates based on the previous year’s costs, anything added to the portfolio in the coming year will not be recovered in rates until the following year. Up to 12 months of O&M for a new power plant that is not included in rates can make a considerable impact to earnings. In other words, shareholders, not customers may pay for the first year of expenses. Forward ratemaking is thus a critical part of the regulatory construct. The correlation between forward ratemaking and realized ROE is clearly shown in Exhibit 3. Exhibit 3: Impact of Regulatory Lag on Realized ROE Rating Forward/ Historical Ratemaking 2009 Realized ROE NEE SP Forward 12.7% SO O Forward 12.3% TE SP Forward 10.9% CMS O Forward 10.2% IDA U Forward 8.9% DTE SP Forward 8.6% DUK SP Historical 7.3% UTL SP Historical 7.1% NVE O Hybrid 5.4% PNM* O Forward 4.4% *Forward test year being implemented for the first time in PNM's pending rate case Source: RBC Capital Markets, Company reports, FactSet ROE Band Protects Consumers, Regulators and Companies with Forward Ratemaking Some regulators are hesitant to let utilities charge customers for expenses than have not been incurred. This can manifest through outright denial of the structure, or in regulator pushback on forecasting methodology. The most productive construct for meeting this challenge is using an ROE band. Under this structure, costs are projected based on earning within the band for the upcoming year(s). If utilities earn above the band, the surplus can be credited back to customers, thus providing a safety net of sorts for regulators. Utilities are incentivized to hit the top of the ROE band, and customers share in the spoils if utilities earn above the approved level. Alabama uses ROE band methodology, Florida and Idaho use it for existing temporary rates. c) Large Investments Require Additional Regulatory Support to Maintain Favorable ROEs Failure to earn an allowed ROE can be magnified when utilities make large-scale capital investments. Financing costs incurred during the construction phase are borne by shareholders unless certain regulatory structures are in place. In certain jurisdictions, utilities can recover Allowance for Funds Used During Construction (AFUDC) or include Construction While In Progress (CWIP) in rate base until the plant comes online. For high growth utilities, this regulatory support closes the gap between realized and approved ROE. Investing large amounts of capital in a new power plant is burdensome for utilities, particularly in the midst of a struggling economy. Regulatory structures can reduce the risks of large-scale investments by establishing a long-term planning forecast, pre-approving new capacity, and allowing the aforementioned AFUDC or CWIP in rate base during the construction phase. Ideally, these investments are also considered outside of a general rate case and costs can be recovered immediately once the plant comes online. These parameters are often established on a per project basis, but our general views on the regulatory climates for these investments across our coverage universe are found in Exhibit 4. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 5 Integrated Resource Plans (IRPs), and the Like Many jurisdictions require utilities to file 10-20 year plans outlining capacity, transmission and other system needs. Needs are based on load growth forecasts and updated on a regular basis. These plans give regulators the longer term picture and minimize surprises when new projects are proposed. The routine filings create a window into utility expectations and keep regulators familiar with the bigger picture. Pre-Approval of Large-Scale Projects Most jurisdictions provide a framework for approving major capital projects proposed by the utilities. Certifications that include cost approvals are preferred. Few, if any, of these structures guarantee full cost recovery and timely inclusion in rate case. Although this would be ideal, pre-approval certification generally provides enough surety for utilities to secure reasonable financing terms for the project. AFUDC/CWIP The ability to recover financing costs during construction of a large-scale investment reduces the financial strain on the utilities and supports realization of the approved ROE. Either recognition of AFUDC or the inclusion of CWIP in rate base accomplishes this end satisfactorily. These mechanisms also help utilities secure financing at favorable terms. Exhibit 4: Treatment of Large-Scale Investments Rating Treatment of Large-Scale Investments CMS O Neutral NVE O Mixed PNM O Neutral SO O Favorable TE SP Mixed UTL SP NA DTE SP Neutral DUK SP Mixed NEE SP Mixed IDA UP Neutral Source: RBC Capital Markets, Company reports Other Regulatory Trends: Bandaid Ratemaking: Not Always a Cure Given weak electricity demand during the recession, many utilities earned less than their approved ROEs in 2009/2010. In order to balance the needs of the utilities with affordability for customers, some jurisdictions implemented temporary solutions. These rate mechanisms essentially allow the utilities to borrow from balance sheet surplus items to maintain minimum ROEs. While providing earnings support in the near term, we believe that this bandaid ratemaking can create dangerous precedents in the medium and longer terms. A Disconnect Is Born Under these fixes, approved rates do not reflect the costs of utility service. After the short term fix expires, the original rate deficiency must be added to bills, plus likely increases in costs since the original filing. This creates a bigger rate case the next time around. It seems unlikely that consumer advocates will give the utility credit in hindsight for sparing customers during the previous period. The advocates instead will challenge the higher requested rates. The post-bandaid rate case cycle thus sets up in contrast to our preferred rate case model of small, simple asks. In our coverage universe, IDA and NEE currently operate under temporary rate relief mechanisms. In NEE’s case, the utility can recognize surplus depreciation up to certain amounts in order to reach a minimum ROE. IDA can recognize tax credits towards the GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 6 same end. IDA is expected to file at rate case in 2011 and NEE in 2012. Both IDA and NEE have new generation costs in addition to previous rate deficiencies to include in their respective filings. Without significant economic growth in either jurisdiction, the next rate case cycles may be challenging. Decoupling: Longer Term Agnostic, But In Rising Markets It May Hold Utilities in Check Utilities that were decoupled in 2008 and 2009 benefitted from this structure when electricity demand plummeted. However, as markets stabilize and trends move upward, these same utilities will not be as levered to the rising tide. At this point, we expect companies without full decoupling to outperform decoupled utilities in 2011. Furthermore, when utilities are decoupled, the rates set by regulators are increasingly important. As electricity load grows, the companies do not realize higher revenues without regulatory approval. Energy Efficiency: Recovery, Return, Incentives The most supportive regulatory structures encourage energy efficiency at the utilities by treating costs outside of a general rate case, assuring timely recovery of program costs, allowing a return on investment, and establishing earnings incentives for reaching certain energy efficiency goals. Additionally, frameworks that provide for recovery of lost load due to energy efficiency rise above the rest. This energy-efficiency-only decoupling removes the financial disincentives otherwise associated with energy efficiency programs. Regulatory Conclusions: Detailed Snapshot Below we have developed a regulatory matrix that captures a fuller view of the previously mentioned regulatory elements. We outline our preferred model for these structures and view on favorable jurisdictions for each element. Additionally, we have developed these matrices for each of our covered companies and their associated jurisdictions. They can be found in the appendix to this note, and in the accompanying company notes published today. Exhibit 5: Regulatory Matrix Source: Company reports, RBC Capital Markets 2) Growth: Cleaning and Greening the Fleet We categorize utility growth opportunities into three main baskets: a) Mandatory spending, b) Traditional spending, and c) Bells and Whistles spending. Regulatory Elements Our Preferred Model Favorable Jurisdictions under coverage for each element Companies with favorable exposure General Rate Cases Test Year Forward-looking AL, GA, FL, MS, MI, NM, ID NEE, SO, TE, CMS,DTE Allowed ROE >10.5%, banded AL, GA, MS SO Frequency & Duration File every 2-3 years AL, NV, GA, MS SO, NVE <6 month decision process Success rate >60%NV, MI, GA SO, NVE, CMS (% of request approved) Other Regulatory Mechanisms Decoupling Energy-efficiency-only NM, NV, NC, SC, IN PNM, NVE, DUK Other Recovery Mechanisms (non-rate case) The more the better FL, GA, AL, MI, IN NEE, TE, SO, CMS, DTE Treatment of Capital Projects Long-term planning process GA, MS, FL, ID, MI, IN SO, NEE, IDA Commission Pre-approval Recovery of AFUDC Cost recovery via rider Fuel and Purchased Power 100% pass-thru Only ID falls short of 100%All but IDA Cost recovery via rider (RR) <= Annual recovery Energy Efficiency Recovery of program costs NV, NM, NC, SC, IN NVE, PNM, DUK Recovery of lost revenues Earnings incentives Commission Appointed Most except PNM GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 7 a) Mandatory spending includes investments that are necessary to comply with laws and regulations. In the near term we expect most utility growth projects to revolve around mandatory spending in the form of environmental compliance and Renewable Energy Portfolio (RPS) compliance. b) Traditional spending includes items associated with load growth such as new meters and new capacity. Plans for incremental new capacity have mostly been shelved due to lower demand forecasts, but resumption of load growth could bring this basket into utility outlook discussions in 2011. c) Bells and Whistles spending includes investments that are not necessary in providing utility service, such as smart meters and electric vehicle investments. Smart metering should proceed where it is already planned, but we do not expect new investments in this area across the space in 2011. Electric vehicle infrastructure may make some headlines, but we do not expect these investments on a significant scale in the near term. To compare growth prospects across our universe we use our five-year forward capital spending estimates as a percentage of current enterprise value. This growth metric is shown for our covered companies in Exhibit 6. Although absolute growth levels are important, they must be considered in the context of the associated regulatory environment. Capital spending is only beneficial to the extent that it is reflected in utility revenues, as approved by regulators. Exhibit 6: Growth Metrics Rating 5yr Capex/ Enterprise Value NEE SP 59% DUK SP 58% CMS O 58% IDA U 55% PNM O 53% DTE SP 50% UTL SP 48% SO O 48% NVE O 37% TE SP 30% Industry average = 45% Source: RBC Capital Markets, Company reports, FactSet a) Mandatory Spending Environmental Compliance: You Must Clean It EPA rulemaking in 2011 will likely prompt final fleet decisions by utilities. Over the next five years the resulting compliance plans should occupy much of the total capital spending for the group. Most companies have already retrofit or plan to retrofit plants larger than 400MWs to comply with current regulations. Plants under 200MW will likely be retired. It is the bubble plants of ~200-400MWs that remain uncertain with respect to current regulations. A snapshot of company exposure to current regulations is below. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 8 Exhibit 7: Coal-at-Risk as % of Total Regulated Generating Capacity Under Current Regulations 0% 2% 4% 6% 8% 10% 12% 14% 16% CMS DTE DUK IDA NEE NVE PNM SO TE Source: Company reports, RBC Capital Markets Decision-Making for Bubble Plants Utilities have three basic options for the bubble plants: 1) retrofit with appropriate pollution controls, 2) run the plant until the compliance period ends and then retire it, and 3) retire the plant and build new replacement capacity. Considerations for the above include the age of the plant, reserve margins in the operating region, the severity of new regulations and the length of the compliance period, and the regulatory environment for the different options. If new regulations push up the price of total compliance retrofits, it is likely that bubble plants may lean more towards retirement. Final Rulemaking for Environmental Regulations Rulemaking in 2011/2012 revolves around four primary regulations currently being reviewed. Restrictions on NOx and SOx emissions from the Clean Air Transport Rule (CATR), Maximum Achievable Control Technologies (MACT) under the Clean Air Act, Coal Combustion Residuals (CCR) rules, and Section 316(b) under the Clean Water Act relating to cooling water intake structures. While the first three regulations impact primarily coal plants, cooling water intake structures are a consideration for natural gas and nuclear plants as well. Further descriptions of these rules and measures necessary for compliance can be found in Appendix C. Mercury Scenario, In Particular May Present Additional Spending Opportunities Current SOx and NOx restrictions have prompted most companies to add scrubbers and Selective Catalytic Reduction controls to reduce emissions. These retrofits also typically reduce mercury emissions by 80%-85%. The mercury rule that is pending final approval in March 2011 could increase this mercury threshold to >90%. Technology exists to meet this standard in the form of Activated Carbon Injection (ACI) and baghouses at ~$150/kw. In our covered universe, PNM, DUK, and SO would have the most capacity that would fall out of compliance if the new standard is greater than 90%, as shown below. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 9 Exhibit 8: Coal-at-Risk as % of Total Regulated Generating Capacity Under Two Mercury Scenarios 0% 5% 10% 15% 20% 25% 30% 35% 40% 45% CMS DTE DUK IDA NEE NVE PNM SO TE Mercury removal of 80-85%Mercury removal of >90% Source: RBC Capital Markets, Company reports Circling Back To Regulatory Frameworks In Assessing Compliance Spending Opportunities There is no broad stroke that will apply to all utilities when fleet decisions are made. However, those with solid regulatory support should rise above the rest. In the strictest mercury case, for example, DUK and SO would have considerable investments to make. SO has forward ratemaking, a favorable rate case track record, above average ROEs and environmental compliance investments are considered outside of the general rate case process. Considering these factors, environmental spending represents significant earnings potential. Contrasting this model, DUK incurs regulatory lag across its jurisdictions and has average approved ROEs, average rate case results and environmental spending is included in the general rate case process. Although compliance spending will ultimately flow into rates, DUK shareholders will incur some of the costs along the way. Renewable Energy Investments: If You Must, Green It Over half of the states have Renewable Portfolio Standards (RPS) which mandates certain amounts of electricity that must be derived from renewable energy sources. These mandates create opportunities for utilities to grow their rate base despite low consumption forecasts. Most notably in our coverage, NVE, PNM, DTE, and CMS should benefit from investing in renewable energy. Additionally, unregulated subsidiaries at DUK and NEE benefit from renewables growth. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 10 Exhibit 9: Renewable Portfolio Standards Impacting Our Coverage Universe State % Renewable by Year Notes NV 25% 2025 - 5% of requirement must be solar through 2015 - 6% must be solar as of 2016 - Energy Efficiency can be up to 25% of requirement - Progression: 15% by 2011, 18% by 2013, 20% by 2015, 22% by 2020 MI 10% 2015 - Detroit Edison: 300MW of new renewables by 2013 and 600MW by 2015 - Consumers Energy: 200MW of new renewables by 2013 and 500MW by 2015 - Existing renewable energy baseline plus 20%, 33%, 50% of the gap between baseline and 10% in 2012, 2013 and 2014 respectively NC 12.5% 2021 - Solar: 0.2% by 2018 - Energy Efficiency can be up to 25% of requirement - Energy Efficiency can be up to 40% of requirement after 2021 - Progression: 3% by 2012-2014, 6% by 2015, 10% by 2018 NM 20% 2020 - Solar: 20% of requirement (4% of sales) - Wind: 20% of requirement (4% of sales) - Geothermal, biomass, certain hydro facilities and other renewables: 10% of requirement (2% of sales) - Distributed renewables: 3% of requirement (0.6% of sales) OH 12.5% 2025 - Renewables: 12.5% by 2024 (includes solar-electric minimum) - Solar-Electric: 0.5% by 2024 - At least 50% of the renewable energy requirement must be met by in-state facilities, and the remaining 50% with resources that can be shown to be deliverable into the state. - Progression: 1% by 2011, 1.5% by 2012, 2% by 2013 and an additional 1% each year thereafter TX 10,000 MW 2015 - Non-Wind: Goal of 500 MW - Progression: 4,264 MW by 2011, 5,256 MW by 2013 5,880 MW by 2015 Source: U.S. Department of Energy Investing Directly In Renewable Generation Utilities can typically choose between building the renewable generation or contracting for the energy from third parties. If regulators are supportive, utilities benefit by building the generation and adding it to rate base. This is especially true with utilities that have already acquired the necessary skill set for the renewable project. NEE, for example, develops renewable projects in its unregulated subsidiary and is well-positioned to develop similar projects through its utility if FL establishes renewable energy standards. In other cases, we prefer joint ventures with experienced partners until the utility develops the appropriate level of expertise. NVE practices the latter with its wind and geothermal joint ventures. SO also has a solar joint venture. Investing In Renewables Transmission In addition to the renewable generation that is needed to satisfy these requirements, transmission lines are often needed to access the generation. These investments overlap with existing utility expertise and typically provide solid returns. State regulators often prefer utilities to construct and maintain these lines. Regulators can typically keep a closer eye on the utilities than on third party vendors. When competing for these projects, utilities thus may have an advantage in the approval process. Given the availability of renewable energy in NV and its proximity to the high demand market of CA, renewable transmission opportunities should emerge for NVE. b) Traditional Spending Load Growth: Still Playing Catch-Up Weather-adjusted load growth turned positive in most jurisdictions in 2010 and we expect this trend to continue in 2011. Industrial volumes carried the day for most utilities, with residential consumption following to a lesser degree. Also of note, 3Q10 results were strong across the country due to favorable weather in most regions. This may create headwinds for 3Q comps, but over the longer term investors should look beyond the weather impact and evaluate the adjusted load numbers. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 11 Industrial Volumes Up, But Still Below Recent Normals Industrial volumes were up 7% over 2009 levels for most of the year, but still remain below average levels of the past 10 years. Utilities operating in heavy industrial areas benefitted from the upsurge and still have room to grow. However, going into 2011 a comparable 7% jump may be ambitious. We expect steady increases, but on a smaller scale than in 2010. Exhibit 10: Industrial Volumes: 1990-August 2010 0.1% 2.8% 0.5% 3.2% 0.5% 2.1%0.7% -6.4% -0.6% -12.6% 7.0% 0.6% -1.8% 2.2% 0.5% 0.1% 1.6%0.4%1.3% -0.7% 0 200,000 400,000 600,000 800,000 1,000,000 1,200,000 19 9 0 19 9 1 19 9 2 19 9 3 19 9 4 19 9 5 19 9 6 19 9 7 19 9 8 19 9 9 20 0 0 20 0 1 20 0 2 20 0 3 20 0 4 20 0 5 20 0 6 20 0 7 20 0 8 20 0 9 20 0 9 Y T D 20 1 0 Y T D -17.0% -12.0% -7.0% -2.0% 3.0% 8.0% Industrial Consumption (GWh)% Change Source: U.S. Energy Information Administration, RBC Capital Markets Non-Industrial Jurisdictions Regions influenced by the housing market more than heavy industry, such as Florida and Las Vegas, have yet to experience a surge in load growth. Housing metrics in these areas are improving, as seen in the charts below, but the glut of inventory from the housing boom remains an issue. Although it still may take time for housing inventory to clear in some of these regions, directional positives may be sufficient to renew investor interest. Exhibit 11: S&P Case Shiller Home Price Indices '91 '92 '93 '94 '95 '96 '97 '98 '99 '00 '01 '02 '03 '04 '05 '06 '07 '08 '09 '10 0 50 100 150 200 250 300 Source: FactSet Prices Indexed Price Performance Price (Indexed to 100) US National CS Index Tampa CS Index Miami CS Index Las Vegas CS Index Source: FactSet Growth Conclusion: Spending Likely Up From Here The bulk of near term capital spending should pertain to environmental compliance. Considering additional emissions restrictions expected in 2011/2012, we expect that this spending should only increase. Additionally, resumption of load growth across the country should renew traditional spending programs. Although new capacity likely remains beyond the near term at current absolute levels, we GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 12 expect utilities to begin discussing these needs in the next couple of years. Bullish capital spending outlooks support our rising industry multiple for 2011. 3) Unregulated Subsidiaries Unregulated subsidiaries of utilities represent an X factor that could swing investor sentiment in one direction or another. They can make up for lack of utility growth or an unfavorable regulatory mechanism. They can also, however, introduce risk and narrow the investor pool accordingly. We prefer unregulated operations that 1) provide steady cash flows, 2) do not introduce considerable risk, 3) overlap with existing utility expertise, and 4) present growth opportunities. To be considered as a utility first, unregulated subs generally comprise less than 25% of the consolidated entity. Steady Cash Flows: Utility-Like Subsidiaries Energy subs that are heavily contracted over the longer term enhance utility earnings by providing stable returns. Energy infrastructure entities match well with this preferred model. Unregulated generation can also be a fit, providing that commodity exposure is hedged or contracted away. These businesses are typically well understood by utility companies and investors. Marketing and Trading: Common Sub, Common Discount Several utilities engage in marketing and trading commodities in an unregulated subsidiary. The companies are already engaged in these markets in order to secure energy for customers. Extending the involvement into active trading outside of existing needs and assets, however, introduces risks that do not sit well with investors. While strong risk parameters can minimize the downside, the volatility of results cannot always be controlled. Investors rarely assign full credit to these operations. Expertise Overlap We prefer subs where a utility simply extends its core expertise into a related entity, as opposed to investing in new areas of expertise. Spending a disproportionate amount of time on conference calls and presentation slides explaining unregulated subsidiaries detract from the core utility fundamentals. These subs can complicate otherwise straightforward utility stories. Unless the regulated business is well above average, investors are unlikely to take the time to understand and give full credit to a completely different business model. Growth Opportunities: Earnings Accretion Without Ratepayer Strain Utility regulators and ratepayers only tolerate moderate increases from year to year. Unregulated subsidiaries can step in and supplement growth for the consolidated entity. As long as the growth prospects do not add considerably to the utility risk profile, shareholders can benefit from the expansion. Standout Subsidiaries, In Both Directions DTE’s gas pipelines and biomass development businesses, PNM’s First Choice Power retail arm, and the contracted wind assets of DUK and NEE benefit shareholders. On the other hand, marketing and trading at DTE and NEE, and TE’s coal segment introduce too much risk, in our view. A summary of unregulated subsidiaries that impact our covered names is found below in Exhibit 12. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 13 Exhibit 12: Unregulated Subsidiaries Rating Subs Impacting Valuation Overall Rating CMS O Contracted Generation Neutral NVE O None NA PNM O Retail electric Favorable SO O Contracted Generation Favorable TE SP Coal mining; Int'l plants Unfavorable UTL SP None NA DTE SP Energy Trading; Gas Infrastructure Neutral DUK SP Merchant Generation; Int'l plants Unfavorable NEE SP Contracted Generation; Renewable development Favorable IDA U None NA Source: RBC Capital Markets, Company reports 4) Dividend: Steady and Growing In addition to regulatory considerations and growth profiles, utilities must have competitive dividend yields. Companies with strong balance sheets are particularly well-positioned to support consistent, growth dividends. Given the long building cycle for power plants and transmission lines, investors must be paid to wait. While upcoming catalysts can offset this need in the short term, longer term investors put a premium on strong dividend yields. Exhibit 13: Balance Sheet and Dividend Metrics Total Debt ($MM) Market Cap ($MM) % Debt/Total Cap S&P500 Rating Moody’s Rating Dividend Yield Duke Energy Corp. DUK $18,291 $23,497 44% A- Baa2 5.5% Southern Co. SO $20,530 $31,777 48% A Baa1 4.8% NextEra Energy Inc NEE $20,468 $21,804 51% A- Baa1 3.8% Large Cap Average 49% 4.6% PNM Resources Inc. PNM $1,760 $1,143 44% BB- Ba2 3.9% IDACORP Inc. IDA $1,619 $1,823 47% BBB Baa2 3.2% DTE Energy Co. DTE $8,017 $7,724 48% BBB+ Baa2 4.9% Unitil Corp. UTL $335 $250 55% NA NA 6.0% NV Energy Inc. NVE $5,670 $3,318 59% BB Ba3 3.1% TECO Energy Inc. TE $3,417 $3,868 60% BBB Baa3 4.6% CMS Energy Corp. CMS $7,234 $4,576 62% BBB- Ba1 4.5% SMID Cap Average 54% 4.3% Source: RBC Capital Markets, FactSet Valuation Considerations and 2011 Outlook We expect the large cap utilities to trade slightly above current levels in 2011 due to further resumption of load growth and increasing capital spending forecasts as a result of EPA final rulemaking. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 14 • Current multiples are 12.6x for large caps and 12.9x for SMID caps. We expect multiples to improve ~5% to 13.3x 2012 earnings for large caps and to 13.5% 2012 earnings for SMID caps. Long term averages are 13.1x for large caps and 13.3x for SMID caps. • Utilities should benefit from continued weather-adjusted load growth recovery and capital spending increases. • Large caps are more defensive with higher stock liquidity, stronger balance sheets and diversified regulatory platforms. SMID caps, on the other hand, are more levered to economic recovery and we expect them to outperform accordingly. Interest Rates: Ambiguous Multiples Correlation at Current Levels, But Rising Tide Should Lift All Boats Although we do not base our industry multiples on interest rates, there has been industry discussion on the topic. Accordingly, we believe it is beneficial to outline our view on interest rates. Although RBC economists expect interest rates to rise in 2011, we believe that absolute yields are still below the threshold that would impact utilities to a large degree. The most correlated interest rate entity has been the 10yr US Treasuries. Traditionally and theoretically when interest rates rise, utility multiples fall. This has been the case historically until interest rates fall below ~5-6%. Below these levels, however, the traditional negative correlation becomes fuzzy. In fact, as shown in the chart below, the two entities are more positively correlated than negatively correlated below these levels. RBC research forecasts interest rates on 10yr US Treasuries at 3.6% on average in 2011 and up to 4.5% in 2H12. Accordingly, we believe that these levels suggest a continued positive correlation with utility multiples in the near term. Until interest rates rise to compete with utility dividend yields, currently 4.5% on average, we expect both entities to rise together. For more information on RBC’s interest rate forecast, please see the RBC note from 12/10/2010, “Financial Markets Monthly: Getting ready for 2011.” Exhibit 14: U.S. 10yr Treasury Yields vs. Large Cap Utility NTM P/Es 0.00% 1.00% 2.00% 3.00% 4.00% 5.00% 6.00% 7.00% 8.00% 9/95 8/96 6/97 4/98 2/99 12/9 9 10/0 0 08/0 1 06/0 2 05/0 3 03/0 4 01/0 5 11/0 5 09/0 6 07/0 7 05/0 8 03/09 01/10 12/10 0.0x 2.0x 4.0x 6.0x 8.0x 10.0x 12.0x 14.0x 16.0x 18.0x 20.0x 10yr Treasury Yield Large Cap Utilities NTM P/E Source: RBC Capital Markets, FactSet, US Federal Reserve 2011 Company Outlook: We Expect CMS, NVE, PNM, and SO To Outperform The Space. For more detailed views on these companies, please see our company notes of the same date. Here again we review our coverage via the Scouting Report. The expanded version below provides the supporting date as described throughout this note. Shading again reflects our view on elements that we expect to improve (green) or worsen (red) in 2011. GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 15 Exhibit 15: Emily’s Expanded Scouting Report Regulatory Growth Unregulated Subsidiaries Dividend Yield Rating1 RBC 2011 All-in Return Current P/E Premium/ Discount2 General Rate Case Success Forward/ Historical Ratemaking Treatment of Large-Scale Investments 2009 Realized ROE 5yr Capex/ Enterprise Value Key Rating Drivers CMS O 15.5% -8.8% 82% Forward Neutral 10.2% 57% Neutral 4.5% Transformational story NVE O 14.5% -8.6% 72% Hybrid Mixed 5.4% 37% NA 3.1% Rate relief should increase ROE PNM O 17.3% -12.7% 69% Forward Neutral 4.4% 51% Favorable 3.8% Regulatory progress = investor confidence SO O 12.6% 12.1% 70% Forward Favorable 12.3% 48% Favorable 4.9% Industry-leading fundamentals TE SP 9.6% -7.4% 61% Forward Mixed 10.9% 29% Unfavorable 4.6% Coal risk UTL SP 10.8% 4.7% 70% Historical NA 7.1% 47% NA 6.0% Rate case risk in new region DTE SP 10.5% -8.3% 57% Forward Neutral 8.6% 50% Neutral 4.8% Rate case risk, Energy Trading DUK SP 12.4% 1.4% 64% Historical Mixed 7.3% 58% Unfavorable 5.6% Rate case risk, IN investigation NEE SP 9.4% -12.6% 8% Forward Mixed 12.7% 58% Favorable 4.1% Regulatory overhang, quiet subs IDA U 8.0% -4.6% 43% Hybrid Neutral 8.9% 55% NA 3.3% Rate case risk, weak dividend 1) O= Outperform, SP= Sector Perform, U= Underperform 2) P/E premium/discount to either SMID Cap or Large Cap averages, as appropriate. Source: RBC Capital Markets, Company reports, FactSet CMS Energy Corp. (CMS): Outperform Transformational Story, Quieter Regulatory Year, Fleet Decisions Possible In recent years, CMS has ample growth opportunities and a favorable regulatory structure to support the capital spending plan. With these fundamentals in place and the recent dividend increase, CMS’s current 9% trading discount is unwarranted and should improve in 2011. Key 2011 CMS Catalysts Include: • Gas rate case decision • Favorable realized ROE • Continued investor turnover with increased dividend Investment Risks: • Unfavorable regulatory outcomes • Decoupling lessens leverage to economic recovery • Cost overruns on pollution control installation NV Energy Inc. (NVE): Outperform High Spend Transitioning Into Earnings Growth NVE is winding down from a high capital spending phase and rate case activity in 2011 should translate these investments into earnings growth. The company’s regulatory structure leaves room for improvement, but general rate case results have been favorable to NVE. As the gap between approved and realized ROE narrows, NVE should outperform its peers. The company currently trades at an (11%) discount to the group which should improve as rate relief comes into view. Key 2011 NVE Catalysts Include: • NV-N rate case decision • Possible 1H11 equity issuance • Closing of CA asset sale • NV-S rate case filing Investment Risks: • Unfavorable regulatory outcomes • Continued housing market weakness • Equity issuance higher than expected GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 16 PNM Resources, Inc. (PNM): Outperform Catalyst Rich 2011 Marked By Regulatory Catch-Up With favorable outcomes in its pending rate cases PNM should begin closing the gap between its authorized ROE and its realized ROE in 2011. Furthermore, important precedents being considered in New Mexico and Texas could solidify the regulatory structures. This would give investors and credit agencies greater confidence in the respective jurisdictions. Possible credit upgrades, dividend increase discussions, and growth plans at PNM’s unregulated businesses are all likely on the table following reasonable regulatory results. PNM currently trades at a (18%) discount to the group, which we expect to erode as positive catalysts are realized. Key 2011 PNM Catalysts Include: • Rate cases in NM, FERC • Energy Efficiency incentives • Solar development progress Investment Risks: • Unfavorable regulatory outcomes • Continued economic weakness in NM, TX • Margin pressure at First Choice Power Southern Company (SO): Sector Perform Favorable Regulatory Environment and Growth Prospects Already Priced In Southern Company leads the industry in countless metrics. It demonstrates operational, financing, and development prowess across its enterprises. These skills, combined with favorable regulatory frameworks and a solid growth pipeline position SO perpetually at the top of the class. Key 2011 SO Catalysts Include: • AP1000 design certification, COL • Vogtle 3&4 cost updates 2/11, 8/11 Investment Risks: • Cost overruns and project delays • Unfavorable regulatory outcomes • Stricter than expected EPA timelines IDACORP, Inc. (IDA): Underperform Big Ask and Low Dividend Yield Present Challenges In 2011 After 2011, temporary rate support expires and tax settlement impacts go away. IDA then must face the existing rate deficiency on top of new expenses associated with the Langley Gulch power plant. Given its recent rate case struggles and economic weakness in ID, rate case risk may be elevated. Further out the company has favorable growth from transmission projects, but with the current low dividend yield, investors are not being paid to wait for this growth to develop. Accordingly, we expect IDA to underperform the group in the near term. IDA currently trades at a (4%) discount which adequately reflects the regulatory risk anticipated in 2011/2012. Key 2011 IDA Catalysts Include: • Rate case filing • Tax settlement Investment Risks: • Unfavorable regulatory outcomes • Decoupling lessens leverage to economic recovery • Cost overruns at Langley Gulch power plant GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 17 DTE Energy Co. (DTE): Sector Perform Rate Case Activity Offsets Favorable Growth Profile in the Near Term DTE is in the midst of a robust capital spending phase to bring its generation fleet up to increasingly strict environmental standards. Although spending at these levels can strain the balance sheet, we believe that the constructive regulatory environment in MI should minimize this risk and allow the company to realize steadily growing earnings and perform in line with peers. Key 2011 DTE Catalysts Include: • Rate case decision at electric utility • Extension of Steel Industry Fuel tax credit • Fleet decisions from EPA final rulemaking Investment Risks: • Unfavorable regulatory outcomes • Continued weakness in natural gas prices • Energy trading volatility Duke Energy Corp. (DUK): Sector Perform Regulatory Bumps Coming, But Investors Are Paid To Wait Much attention has been paid to DUK’s OH customer switching issues and now focus is directed on the IN regulatory situation. With the new ESP in OH and Edwardsport settlement resolution expected in the near term, investors should begin looking forward. After winding down its environmental compliance program, rate relief, load growth and nuclear development should take center stage. We believe that uplift from the OH and IN resolutions and the strong dividend yield may be offset by rate cases in the Carolinas in 2011 and expect DUK to perform in line with its peers accordingly. Key 2011 DUK Catalysts Include: • Carolina rate cases • Legislative efforts to mitigate new nuclear risks • Resolution of Edwardsport settlement agreement Investment Risks: • Unfavorable regulatory outcomes • Cost overruns at construction projects • Unfavorable final EPA rules NextEra Energy Inc. (NEE): Sector Perform Regulatory Headwinds Remain NEE has withstood a considerable regulatory setback due to favorable non-rate case framework and support from its unregulated operations. Going forward the utility remains highly levered to the FL economy with its anticipated 2012 rate case filing. Although challenges remain for NEE, we believe that most of the stock damage has been done and expect NEE to trade with the group in 2011 as a Sector Perform. Key 2011 NEE Catalysts Include: • Improving economic trends • New wind/solar project announcements Investment Risks: • Further weakness in FL economy • Pullback in renewable energy mandates • Sluggish power markets TECO Energy Inc. (TE): Sector Perform Florida Economic Recovery Pairs Well With Recent Rate Relief and Restructuring, but Coal Drag Likely To Persist While FL economic recovery may be a slow climb, we anticipate positive trending in 2011. A resumption of load growth, the 2009 rate increase, lower cost structure and minimal capital spending needs should position the company favorably in 2011. However, TE’s coal business offsets some of these drivers. We expect negative headlines and cost pressures to continue throughout the year and to hold the stock in check with its peers. Key 2011 TE Catalysts Include: • Improving FL economic metrics • Potential FL renewable energy legislation • Potential new coal regulations Investment Risks: • Rising coal costs in Central Appalachia • Continued weakness in FL economy GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 18 Unitil Corp. (UTL): Sector Perform Rate Case Risk Offset by Favorable Dividend Yield UTL has been a dividend-play during the recession and associated market turmoil. Although the dividend will remain a critical part of the picture, the company’s regulatory efforts should be the focus in 2011. We expect the regulatory risk associated with the rate case activity to capture attention and keep UTL in check with its peers. Key 2011 TE Catalysts Include: • Rate cases in NH, MA and ME Investment Risks: • Unfavorable regulatory outcomes • Severe weather events • Weakness in New England economy GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 19 Appendix A: Regulated Utilities Comparables Valuation Regulatory Growth Rating3 RBC 2011 All-in Return 1/7/2011 Price Target Price Dividend Yield4 Current Multiple RBC Target Multiple Current Premium/ Discount RBC Estimated Premium/ Discount RBC 2012 EPS Estimate General Rate Case Success Forward/ Historical Ratemaking Treatment of Large-Scale Investments 2009 Realized ROE 5yr Capex/ Enterprise Value Key Rating Drivers RBC Risk Rating SMID Caps1 CMS O 15.5%$18.91 $21 4.5%11.9x 13.0x -8.7%-4.0%$1.59 82%Forward Neutral 10.2%57%Neutral Transformational story AVG NVE O 7.5%$14.37 $16 3.1%11.9x 12.7x -8.6%-6.0%$1.21 72%Hybrid Mixed 5.4%37%NA Rate relief should increase ROE AVG PNM O 9.8% $13.21 $15 3.8% 11.3x 12.2x -12.7% -10.0% $1.16 69%Forward5 Neutral 4.4% 52% Favorable Regulatory progress = investor confidence AVG DTE SP 8.4%$46.34 $49 4.8%11.9x 12.4x -8.3%-8.0%$3.88 57%Forward Neutral 8.6%50%Neutral Rate case risk, Energy Trading AVG TE SP 4.1%$18.09 $19 4.6%12.0x 12.2x -7.4%-10.0%$1.50 61%Forward Mixed 10.9%30%Unfavorable Coal risk AVG UTL SP 10.8%$22.90 $24 6.0%13.6x 14.0x 4.7%4.0%$1.68 70%Historical NA 7.1%48%NA Rate case risk in new region AVG IDA U 8.0%$37.22 $39 3.3%12.4x 13.1x -4.6%-3.0%$3.00 43%Hybrid Neutral 8.9%54%NA Rate case risk, weak dividend AVG SMID Cap Peer Average SMID 4.3%13.0x 13.5x Large Caps2 SO O 10.0%$38.08 $41 4.9%14.3x 15.2x 12.1%14.0%$2.67 70%Forward Favorable 12.3%48%Favorable Industry-leading fundamentals AVG DUK SP 12.4%$17.79 $19 5.6%12.9x 13.4x 1.4%1.0%$1.38 64%Historical Mixed 7.3%58%Unfavorable Rate case risk, IN investigation AVG NEE SP 9.4%$52.22 $55 4.1%11.1x 11.7x -12.6%-12.0%$4.70 8%Forward Mixed 12.7%58%Favorable Regulatory overhang, quiet subs AVG Large Cap Peer Average 4.3%12.7x 13.3x RBC EPS Estimates 1Q10 2Q10 3Q10 4Q10E 2010E 2011E 2012E CMS $0.38 $0.26 $0.52 $0.20 $1.34 $1.43 $1.59 DTE $1.38 $0.39 $0.96 $0.80 $3.64 $3.69 $3.88 DUK $0.36 $0.34 $0.51 $0.23 $1.44 $1.32 $1.38 IDA $0.32 $0.30 $1.39 $0.53 $2.53 $2.79 $3.00 NEE $0.94 $1.11 $1.46 $0.83 $4.32 $4.45 $4.70 NVE -$0.01 $0.16 $0.77 -$0.06 $0.87 $1.01 $1.21 PNM $0.06 $0.21 $0.63 -$0.03 $0.88 $0.82 $1.16 SO $0.60 $0.61 $0.97 $0.20 $2.36 $2.49 $2.67 Unregulated Subsidiaries '06 '07 '08 '09 '10 40 50 60 70 80 90 100 110 120 130 140 Source: FactSet Prices S&P 500 vs. SMID Caps vs. Large Caps Trailing 5 yrs Indexed Price Performance Price (Indexed to 100) S&P 500 SMID Caps Large Caps SO $0.60 $0.61 $0.97 $0.20 $2.36 $2.49 $2.67 TE $0.34 $0.37 $0.41 $0.21 $1.33 $1.37 $1.50 UTL $0.60 -$0.19 -$0.01 $0.61 $1.02 $1.37 $1.68 1) SMID Cap Peer Group includes: AEE, BKH, CNP, CEG, NU, NST, OGE, POM, POR, PNY, PNW, UIL, WR and WEC, in addition to covered names. 2) Large Cap peer group includes: AEP, ED, D, PCG, PGN, SRE and XEL, in addition to covered names. 3) O=Outperform, SP=Sector Perform, U=Underperform 4) Based on RBC 2011 Dividend and EPS estimates and current prices 5) New rule, being implemented for the first time in PNM's rate case Source: RBC Capital Markets estimates, FactSet '06 '07 '08 '09 '10 40 50 60 70 80 90 100 110 120 130 140 Source: FactSet Prices S&P 500 vs. SMID Caps vs. Large Caps Trailing 5 yrs Indexed Price Performance Price (Indexed to 100) S&P 500 SMID Caps Large Caps GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 20 Appendix B: Regulatory Matrix for companies under coverage CMS Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model MI - 100% General Rate Cases Test Year ++++Forward-looking Forward-looking Allowed ROE =>10.5%, banded 10.7%, unbanded Frequency & Duration of rate cases =File every 2-3 years Filed annually <6 month decision process 12 month decision process Success rate (% of request approved)++++>60%80% blended, 2009-2010 Other Regulatory Elements Decoupling —Energy-efficiency-only Full decoupling Recovery Mechanisms outside of general rate case process ++++The more the better Fuel, Energy Efficiency, Renewables Treatment of Large Capital Projects =Long-term planning process Nothing formal Pre-approval by Commission Certificate of Need process AFUDC/CWIP in rate base AFUDC recovery Cost recovery outside of base rates Recovery in base rates Fuel and Purchased Power =100% pass-thru 100% pass-thru Cost recovery outside of base rates Cost recovery outside of base rates Reconciliation at least annually Reconciliation at least annually Energy Efficiency ++++Recovery of program costs Recovery of program costs Recovery of lost sales revenue Recovery of lost sales revenue Earnings incentives Earnings incentives Commission ++++Appointed Appointed Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 21 DTE Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model MI - 100% General Rate Cases Test Year +Forward-looking Forward-looking Allowed ROE +>10.5%, banded 11.0%, unbanded Frequency & Duration of rate cases =File every 2-3 years Filed ~annually <6 month decision process 12 month decision process Success rate (% of request approved)=>60%60% blended, 2009-2010 Other Regulatory Elements Decoupling =Energy-efficiency-only (EE-only)Full decoupling, moving to EE-only Recovery Mechanisms outside of general rate case process +The more the better Fuel, Energy Efficiency, Renewables Treatment of Large Capital Projects =Long term planning process Nothing formal Pre-approval by Commission Certificate of Need process AFUDC/CWIP in rate base AFUDC recovery Cost recovery outside of base rates Recovery in base rates Fuel and Purchased Power =100% pass-thru 100% pass-thru Cost recovery outside of base rates Cost recovery outside of base rates Reconciliation at least annually Reconciliation at least annually Energy Efficiency +Recovery of program costs Recovery of program costs Recovery of lost sales revenue Recovery of lost sales revenue Earnings incentives Earnings incentives Commission +Appointed Appointed Source: RBC Capital Markets, Company reports DUK Regulatory Matrix Regulatory Structure Elements Blended Rating Our Preferred Model NC - 49% rate base IN - 25% rate base SC - 15% rate base OH - 8% rate base KY - 3% rate base General Rate Cases Test Year -Forward-looking Historical Historical Historical Historical Historical Allowed ROE =>10.5%, banded 10.70% 10.50% 11.00% 10.60% 10.40% Frequency & Duration =File every 2-3 years Filed as needed Filed as needed, none since merger File as needed File as needed File as needed <6 month decision process 5 months to settle in 2009 NA 4 months to settle in 2009 9 months in 2008 5 months 2008/2009 Success rate =>60% 63.5% in 2009 NA 55.0% 60.0% 74.0% (% of request approved) Other Regulatory Elements Decoupling ++++Energy-efficiency-only Energy-efficiency-only Energy-efficiency-only Energy-efficiency-only Energy-efficiency-only None Other Recovery Rechanisms (non-rate case) =The more the better Fuel, Energy Efficiency Fuel, Demand side management, Smart Grid, Pollution controls and emissions, MISO costs Fuel, Demand side management, pension, storm reserve, nuclear insurance Fuel, environmental spending, energy efficiency, smart grid, bad debt, wind storm cost recovery Fuel =Long-term planning process Integrated Resource Plan Integrated Resource Plan Integrated Resource Plan N/A - T&D only Integrated Resource Plan Commission Pre-approval Certificate of Public Convenience & Necessity Certificate of Need Certificate of Need Recovery of AFUDC CWIP in rate base, nuclear development costs IGCC costs recovered as incurred Nuclear CWIP via rider Cost recovery via rider Included in base rates Rider for IGCC CWIP Included in base rates Included in base rates Fuel and Purchased Power =100% pass-thru 100% pass-thru 100% pass-thru 100% pass-thru 100% pass-thru 100% pass-thru Cost recovery via rider (RR)RR RR RR RR RR <= Annual recovery Annual Qtr Qtr Qtr electric, Monthly gas Monthly Energy Efficiency ++++Recovery of program costs Recovery of program costs Recovery of program costs Recovery of program costs Recovery of program costs None yet Recovery of lost revenues Recovery of lost revenues Recovery of lost revenues Recovery of lost revenues Recovery of lost revenues Earnings incentives Earnings incentives Pending before Commission Earnings incentives Earnings incentives Commission =Appointed Appointed Appointed Elected Appointed Appointed Treatment of Capital Projects Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 22 IDA Regulatory Matrix Regulatory Structure Elements Blended Rating Our Preferred Model ID ~95% net income General Rate Cases Test Year =Forward-looking Forward-looking Allowed ROE ->10.5%, banded 9.5% floor Frequency & Duration -File every 2-3 years Filed as needed <6 month decision process 9-12+ months Success rate ->60%45% (% of request approved) Other Regulatory Elements Decoupling =Energy-efficiency-only Almost full decoupling Other Recovery Rechanisms (non- rate case) =The more the better Fuel, Load Growth, Fixed Cost Adjustments Treatment of Capital Projects ++++Long-term planning process Integrated Resource Plan Commission Pre-approval Certificate of Public Convenience & Necessity Recovery of AFUDC Open to CWIP, untested Cost recovery via rider Included in base rates Fuel and Purchased Power -100% pass-thru Pass-thru with 95/5 sharing of over/under Cost recovery via rider (RR)Cost recovery outside of base rates <= Annual recovery Reconciliation annually Energy Efficiency =Recovery of program costs Recovery of program costs Recovery of lost revenues Decoupled for lost revenues Earnings incentives No earnings incentive Commission =Appointed Appointed Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 23 NEE Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model* FL ~50% net income General Rate Cases: Test Year ++++Forward-looking Forward-looking Allowed ROE —>10.5%, banded 10%, banded until 2012 Frequency & Duration =File every 2-3 years Filed as needed <6 month decision process Year+ 2009, 6 months 2005 Success rate —>60%7.5% 2010 (% of request approved) Other Regulatory Mechanisms Decoupling =Energy-efficiency-only None Other Recovery Rechanisms (non-rate case)++++The more the better Fuel, Environmental Compliance, Energy Efficiency, Renewables, Capacity Treatment of Capital Projects ++++Long-term planning process 10yr site plan Commission Pre-approval Determinination of Need Recovery of AFUDC Nuclear AFUDC, development costs Cost recovery via rider Rider recovery Fuel and Purchased Power =100% pass-thru 100% pass-thru Cost recovery via rider Cost recovery via rider <= Annual recovery Annual Energy Efficiency —Recovery of program costs Recovery of program costs Recovery of lost revenues No recovery Earnings incentives No Earnings incentives Commission ++++Appointed Appointed Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 24 NVE Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model NV - 100% General Rate Cases: Test Year —Forward-looking Hybrid Allowed ROE =>10.5%, banded 10.5%, unbanded Frequency & Duration ++++File every 2-3 years Filed every 3 years <6 month decision process 6 months Success rate ++++>60%73% blended in 2007/2008 (% of request approved) Other Regulatory Elements: Decoupling ++++Energy-efficiency-only Energy-efficiency-only Other Recovery Mechanisms (non- rate case) The more the better Energy efficiency, fuel Treatment of Capital Projects =Long-term planning process Integrated Resource Plan (IRP) Commission Pre-approval Through IRP Recovery of AFUDC CWIP in rate base for critical facilities Cost recovery via rider Recovery in base rates Fuel and Purchased Power ++++100% pass-thru 100% pass-thru Cost recovery via rider (RR)RR <= Annual recovery Quarterly adjustments, annual true-up Energy Efficiency ++++Recovery of program costs Recovery of program costs Recovery of lost revenues Recovery of lost sales revenue Earnings incentives Earnings incentives Commission ++++Appointed Appointed Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 25 PNM Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model* NM - 75% rate base TX - 20% rate base General Rate Cases Test Year =Forward-looking Forward-looking Historical Allowed ROE =>10.5%, banded 10.50%10.30% Frequency & Duration of rate cases =File every 2-3 years Filed as needed Filed as needed <6 month decision process 9 months 2009, >1 yr 2008 6 months Success rate (% of request that is approved)=>60% 69% in 2009, 44% in 2008 52% in 2009 Other Regulatory Elements Decoupling ++++Energy Efficiency-only Energy Efficiency-only None Recovery Mechanisms outside of general rate case process =The more the better Fuel, Energy Efficiency Purchased power Treatment of Large Capital Projects ++++Pre-approval by Commission Certificate of Public Convenience & Necessity N/A Long-term planning Integrated Resource Plan Recovery of AFUDC No recovery Assurance of total cost recovery No assurance Cost recovery outside of base rates Included in base rates Fuel and Purchased Power =100% pass-thru 100% pass-thru 100% pass-thru Cost recovery outside of base rates Cost recovery outside of base rates Cost recovery outside of base rates Reconciliation at least annually Reconciliation annually Reconciliation annually Energy Efficiency ++++Recovery of program costs Recovery of program costs AMI cost recovery plus return Recovery of lost sales revenue Recovery of lost sales revenues Earnings incentives Earnings incentives Commission —Appointed Elected Appointed Source: RBC Capital Markets, Company reports SO Regulatory Matrix Blended Regulatory Elements Our Preferred Model Rating GA ~47% net income AL ~34% net income MS ~5% net income FL ~5% net income General Rate Cases Test Year Forward-looking ++++Forward-looking Forward-looking Forward-looking Forward-looking Allowed ROE >10.5%, banded ++++11.25%, banded 13.0-14.5%, banded Banded, above 13%11% Frequency & Duration File every 2-3 years ++++ Filed every 3 years Annual RSE filings Annual PEP filing Filed as needed <6 month decision process 6 months ~1 month ~1 month 9 months Success rate >60%=70% settlement pending N/A N/A 75% in 2001 (% of request approved) Other Regulatory Mechanisms Decoupling Energy-efficiency-only =None None None None Other Recovery Mechanisms (non-rate case) The more the better ++++Fuel, Environmental Compliance costs, Natural Disaster reserve Fuel, New Capacity, Environmental compliance, Natural Disaster reserve Fuel, Environmental compliance Fuel, Environmental Compliance, Energy Efficiency, Renewables Treatment of Capital Projects Long-term planning process ++++ Integrated Resource Plan None Integrated Resource Plan 10yr site plan Commission Pre-approval Certificate of Need Rate Certification New Plant Certificate of Need Determinination of Need Recovery of AFUDC Recovery for nuclear O&M, depreciation, ROI CWIP recovery AFUDC, development costs Cost recovery via rider Recovery in Rate Base Rider recovery Rider recovery Rider recovery 100% pass-thru =100% pass-thru 100% pass-thru 100% pass-thru 100% pass-thru Cost recovery via rider (RR)RR RR RR RR <= Annual recovery Annual Annual Annual Annual Energy Efficiency Recovery of program costs =Recovery of program costs No mandates No mandates Recovery of program costs Recovery of lost revenues No recovery No recovery Earnings incentives Return on program costs No Earnings incentives Commission Appointed —Elected Elected Elected Appointed Fuel and Purchased Power Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 26 TE Regulatory Matrix Regulatory Structure Elements Rating Our Preferred Model* 100% Florida General Rate Cases Test Year ++++Forward-looking Forward-looking Allowed ROE =>10.5%, banded 11.20% Frequency & Duration of rate cases —File every 2-3 years Filed as needed <6 month decision process 8-9 months Success rate (% of request that is approved)++++>60%62% in 2009 Other Regulatory Elements Decoupling =Energy Efficiency only None Recovery Mechanisms outside of general rate case process ++++The more the better Fuel, Environmental compliance, Capacity costs, Energy efficiency, storm damage Treatment of Capital Projects ++++Pre-approval by Commission Determination of Need Long-term planning 10yr site plan, filed every 3 years Recovery of AFUDC Recovery of AFUDC, development costs Assurance of total cost recovery Costs approved, recovery not guaranteed Cost recovery outside of base rates Capacity Cost Recovery Clause Fuel and Purchased Power =100% pass-thru 100% pass-thru Cost recovery outside of base rates Cost recovery outside of base rates Reconciliation at least annually Reconciliation annually Energy Efficiency =Recovery of program costs Recovery of program costs Recovery of lost sales revenue No recovery of lost sales revenues Earnings incentives No earnings incentives Commission ++++Appointed Appointed Source: RBC Capital Markets, Company reports UTL Regulatory Matrix Blended Regulatory Elements Rating Our Preferred Model NH ~50%MA ~25%ME ~25% General Rate Cases: Test Year —Forward-looking Historical Historical Historical Allowed ROE —>10.5%, banded 9.67%10-10.25%NM Frequency & Duration =File every 2-3 years File as needed File as needed File as needed <6 month decision process 3/9 months, stepped ~1 month ~9 months Success rate +>60%80%64%N/A (% of request approved) Other Regulatory Mechanisms Decoupling =Energy-efficiency-only None In next rate case None Other Recovery Rechanisms (non-rate case) =The more the better Fuel, Storm Reserve Fuel Fuel Treatment of Capital =Long-term planning process None None None Projects Commission Pre-approval Step adjustment proposed Recovery of AFUDC Cost recovery via rider Fuel and Purchased Power =100% pass-thru 100% pass-thru 100% pass-thru 100% pass-thru Cost recovery via rider (RR)RR RR RR <= Annual recovery 6/12 months Annual Annual Energy Efficiency =Recovery of program costs Recovery of program costs Recovery of program costs Recovery of program costs Recovery of lost revenues None Decoupled in next rate case None Earnings incentives Return on program costs Return on program costs Return on program costs Commission +Appointed Appointed Appointed Appointed Source: RBC Capital Markets, Company reports GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 27 Appendix C: Environmental Regulations on the Horizon Clean Water Act Section 316(b): Cooling Water Intake Structures Requires that cooling water intake structures minimize adverse environmental impacts • Parts of the rule were overturned by the U.S. Court of Appeals in 2007 • EPA proposed replacement rule in September • Costs and benefits of controls may be considered • Anticipated Implementation period: beginning in 2014, lasting five years Impacts coal, gas, and nuclear plants Solutions: Mesh netting systems, cooling towers Cooling towers estimated to cost $170-$440/gallons per minute according to NERC Maximum Available Control Technology (MACT) under Clean Air Act Average emission limitation achieved by the best performing 12% of the existing sources • Must propose MACT rule by March 16, 2011, finalize by November 16, 2011 • Mandatory three-year compliance timeframe Impacts coal and oil-fired plants Solutions: Scrubbers for all coal types plus Selective Catalytic Reduction controls (SCRs) for bituminous coal and Activated Carbon Injection (ACI) & Baghouses for sub-bituminous and lignite coals On average, ACI/Baghouses cost $150/kw, Scrubbers $400-$600/kw, SCRs $350-$500/kw Clean Air Transport Rule (CATR) To control long-range transport of power plant SOx/NOx emissions • Draft rule proposed July 2010, finalize March 2011 • Proposed cap and trade program to start 1/1/2012, stricter compliance level starting in 2014 Impacts mostly eastern U.S. coal plants Solutions: Scrubbers and SCRs Coal Combustion Residuals (CCR) Coal ash disposal parameters to protect groundwater • Draft rule proposed May 2010, final rule expected in 2011 • Compliance to start 2013-2015, full compliance by 2018 Impacts coal plants with wet storage ash ponds Solutions: Dry landfill storage rather than wet ash pond storage Costs for conversion are site-specific, but range from $100-$150 per location GRRRRRowth = High Voltage InvestmentJanuary 10, 2011 28 Required Disclosures Conflicts Disclosures This product constitutes a compendium report (covers six or more subject companies). 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Past performance is not indicative of future performance. .® Registered trademark of Royal Bank of Canada. RBC Capital Markets is a trademark of Royal Bank of Canada. Used under license. Copyright © RBC Capital Markets, LLC 2011 - Member SIPC Copyright © RBC Dominion Securities Inc. 2011 - Member CIPF Copyright © Royal Bank of Canada Europe Limited 2011 Copyright © Royal Bank of Canada 2011 All rights reserved GRRRRRowth = High Voltage InvestmentJanuary 10, 2011